Withdrawn

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"OSG, based in New York, said Feb. 10 that the pool of 45 supertankers from seven owners in which its carriers trade will no longer go to Iran... Four OSG-owned ships, managed by Tankers International LLC, called at the country's biggest crude-export terminal in the past year, ship tracking data compiled by Bloomberg show...OSG's Overseas Rosalyn, which can carry about 2 million barrels, arrived at Kharg Island on Jan.27 and departed the next day, tracking data compiled by Bloomberg show.  It left abour 16 feet deeper in the water, an indication it loaded cargo...OSG complies with all U.S and European laws and its headquarters in New York doesn't manage charters, OSG Chief Executive Officer Morten Arntzen said in an email Jan. 30."  (Bloomberg, "Iran Sanctions Tighten as OSG to Frontline Halt Crude Cargo," 2/13/12 )

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OSG is "the second largest publicly traded oil tanker company in the world, measured by number of vessels." (Company website. "Corporate Profile")

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"According to marine transport site, Equasis, ships owned by US shipping company, Overseas Shipholding Group Inc. (NYSE: OSG), partly owned [by] Oudi Recanati and Ariel Recanati, have docked in Iran. An examination of Equasis's website found that OSG oil tanker Overseas Tanabe docked at Khark in Iran in September 2009. The ship flies under the Marshall Islands flag." (Globes. "Recanti's OSG ships also docked in Iran," 6/1/11)

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Listed by U.S. Government as doing business in Iran. (U.S. Securities and Exchange Commission, List of Companies Doing Business With State Sponsors Of Terror, Removed from the internet in July of 2007)

OMV is listed as a prohibited company in the March 2020 and March 2021 Report to the New Jersey Legislature Iran Divestment Act. 

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"The company was reported as potentially signing an MOU to develop the Band Karkheh oilfield. In 2018 CalPERS designated the company as under review. In 2019 CalPERS changed the designation to “being monitored” because CalPERS’ initial screening has not identified the company as having involvement in the regions and/or activities targeted by the Act. CalPERS has maintained the company in “monitor” status for 2020. CalPERS continues to monitor the company for possible changes in status relevant to the Act."

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"OMV signed an MOU with Dana Energy and NIOC to develop the Band Karkheh oilfield. In 2017, CalSTRS designated OMV as “Being Monitored” for potentially having new ties to Iran and subsequently maintained the status after reviewing the company’s business and internal controls and determined to monitor its interest in the Band Karkheh oilfield. In 2018, the company announced it will pull out of Iran when seismic studies are completed. In 2020, CalSTRS removed OMV after further review of the company’s internal controls to prevent sanction violations."

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OMV is listed in the March 1, 2019, Report to the New Jersey Legislature Iran Divestment Act. 

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In 2017, CalSTRS designated OMV as “Being Monitored” for potentially having new ties to Iran and subsequently maintained the “Being Monitored” designation after reviewing the company’s business and internal controls and deciding to monitor their interest in the Band Karkheh oilfield. In 2018, the company announced it will pull out of Iran when seismic studies are completed. CalSTRS is maintaining a “Being Monitored” designation until the pull out is completed. OMV has signed MOU with Dana Energy and NIOC to develop the Band Karkheh oilfield.

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"Austria’s energy giant OMV says it plans to cease its operations in Iran amid growing signs that the United States is preparing to re-impose sanctions against the country. OMV Chief Executive Rainer Seele told Reuters that his company planned to conclude a seismic studies project in Iran but would not pursue projects further. “Let’s face it, you cannot simply carry on in Iran,” he said. “US sanctions are a much bigger risk for OMV’s business than any possible compensation that Europe … could offer.”" (June 15, 2018).

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"Austrian energy group OMV is continuing with planned Iranian energy projects despite the United States’ withdrawal from a nuclear pact with Tehran, but said on Tuesday it had made no investments there yet." (5/22/2018).

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"Austrian integrated oil and gas company, OMV, is seeking to expand cooperation with the National Iranian Oil Company to secure a footprint in the country's upstream sector, OMV's Orient Upstream general manager said.

"We are very upbeat on the future of collaborations with NIOC and look forward to further our activities in the oil discovery, production and development fields," Kurt Wagner was also quoted as saying by NIOC's portal on Sunday.

He was speaking on the sidelines of Iran Oil Show 2018, the largest annual convention in Iran's petroleum industry in Tehran. In addition to Iranian companies, over 600 representatives from 37 countries have participated in the event.

The official described the two companies' previous cooperation as promising, saying that talks are underway to sign a deal with NIOC, within the framework of Iran Petroleum Contract, the country's new model of contracts for oil and gas projects." (May 8, 2018).

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In 2018 the U.S. state of Iowa listed OMV as an Iran restricted company rendering OMV ineligible for investment and/or state contracting. 

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"Russian oil corporation Gazprom Neft and Austrian OMV AG energy company signed a cooperation agreement on the exploration and assessment of Iranian oil fields at the St. Petersburg International Economic Forum (SPIEF), the Russian company said Friday." (June 2, 2017)

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"Iran's state oil company NIOC is close to finalising a term contract to supply Austrian energy group OMV with 40,000 b/d of Iranian crude, managing director Ali Kardor said. Part of the proceeds for the crude will be used to repay debts Iran owes to the Austrian company for some exploration work carried out in Iran more than a decade ago, he said. "This agreement will help Tehran pay its outstanding debts to OMV," Kardor said in Tehran. OMV carried out exploration work at the Mehr block for five years after it was awarded the rights to explore the license in 2001. It went on to discover the Band-e-Karkheh oil field in 2007, when it was originally estimated to hold 2bn bl of oil. NIOC more than doubled this estimate to 4.5bn bl in 2009 after discovering a new oil layer. Kardor did not clarify what Iran's standing debt was to OMV, but said 7.25pc of the price of these barrels would go towards paying the debt off, with the remainder going to the country's treasury." (Argus Media, "Iran Finalizing Crude Sales Contract With OMV," 5/11/2017).

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"Austria's OMV and Iran's Dana Energy have signed a memorandum of understanding to evaluate possible oil and gas development and redevelopment projects in Iran, the companies said Wednesday, in a development that could open an indirect route for UAE interests to participate in Iran's upstream petroleum sector... the OMV/Dana agreement is unusual in bringing to Iran an international oil company in which an Arabian state entity holds a substantial equity stake, and in teaming up the international partner with an Iranian private-sector petroleum company instead of one owned by Iran's government... OMV is the former state petroleum company of Austria in which Vienna still holds a 31.5% stake. Its second-biggest shareholder, with 24.9%, is Abu Dhabi government-owned International Petroleum Investment Co., which last Saturday became a wholly-owned subsidiary of Mubadala Investment, the newly created Abu Dhabi industrial group with international petroleum assets that include over 800,000 b/d of oil production." ( Platts, "OMV Inks Deal to Access Oil Developments in Iran with Private Iranian Company," 1/25/2017).

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Austria’s OMV is reportedly negotiating with the National Iranian Oil Company (NIOC) over the development of Iran’s Cheshmeh Khosh oil field. Fars news agency reported that a delegation from OMV had met Amir-Hossein Zamaniniya, Iran’s deputy petroleum minister for international affairs, as well as Salbali Karimi, the managing director of the Iranian Central Oil Fields Company (ICOFCO.), to discuss the project. Fars added that talks had already involved the technical points. The field is located in Iran’s western province of Ilam. It is expected to have a production of 18,000 barrels per day of oil and 115 million cubic feet of natural gas once fully developed. (Press TV, "OMV eyeing Iran's Cheshmeh Khosh project," 12/11/2016).

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"In May 2016, the National Iranian Oil Company (NIOC) and OMV signed a Memorandum of Understanding (MoU) concerning the evaluation of five oil fields in the West of Karoun area, for potential future development. The MoU also covers an envisaged cooperation in the area of technology research, crude and petroleum product swap business."  

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Austria's OMV said on Friday it received 1 million barrels of crude oil from Iran in a spot delivery at the Italian port of Trieste which the energy group will send to its two refineries in Austria and Romania. The delivery was Iran's first to OMV since 2012, when sanctions were imposed on the country. OMV is in talks with Iran about future deliveries, although no such contract has been signed yet, a spokesman said. (Reuters, "Iran sends 1 mln barrels of oil to Austria's OMV in spot delivery," 9/16/2016)

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The Chairman and CEO of OMV, Rainer Seele, presented at the Iranian Petroleum and Energy Club (IPEC) Congress, held in Tehran October 19-21, 2015. (IPEC Congress 2015 Program)

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"Austrian energy group OMV wants its expansion in Iran to focus on the oilfields it has already discovered and it is prepared to invest only a limited amount there, Chief Executive Rainer Seele said on Monday. Seele, who is preparing a new strategy aimed at adapting to low oil prices and expanding production cost-efficiently, said he had no interest in a much more expensive gas project in Iran, apparently referring to the massive South Pars gas field. 'At the end of the day for us it is not simply about producing oil or gas -- we want to make profits,' he said at a joint event with Gerhard Schroeder, the former German chancellor who is now an executive for the pipeline consortium Nord Stream... While OMV was keen to move as soon as sanctions are lifted, which he expected to happen in the first or second quarter, Seele said the economic conditions had to be right, and the company would focus on the fields it knows best. 'We discovered two oilfields there,' Seele said." (Reuters, "OMV says wants to focus Iran push on its existing oil finds," 11/9/15)

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"Iran's Oil Minister Bijan Zanganeh said he had met on Wednesday with Austrian oil and gas group OMV and other foreign oil companies as Tehran prepares to offer oilfields, projects and its final investment contract in November. Zanganeh, in Vienna for an OPEC meeting. He declined to name the other firms involved in the talks, held on the executive floor of an international hotel cleared of reporters. 'The companies are coming and visiting. At least they are showing that they are keen on exploring these possibilities, to get prepared for what they want to do,' a source close to the matter said." (Reuters, Iran oil minister meets OMV, other companies in Vienna, 6/11/14)

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"As it tries to lure back oil companies, Iran also signaled it could offer production-sharing agreements in the Caspian Sea. Such deals are considered attractive to companies but haven't been awarded in Iran since the 1970s. Bijan Zanganeh, who was in Vienna for the meeting of the Organization of the Petroleum Exporting Countries, said he had met with executives from Anglo-Dutch oil giant Shell, the world's largest oil trader Vitol, Austria's and Italy's Eni SpA…'With OMV, we discussed about many things and [with] Shell only about the general willingness for cooperation in future and placing the money that we have in account of Shell,' Mr. Zanganeh told reporters." (Wall Street Journal, "European Energy Companies Meet With Iranian Oil Minister," 12/5/13)

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"This year, 166 Chinese companies are present at the fair compared to 100 companies last year,' a senior oil ministry official said. 'The number of foreign companies are up 35 percent,' to 496 out of the total 1,550, he said. He said that despite UN sanctions and bilateral punitive measures by the United States and the European Union against Iran, 'Germany is present with 64 companies, Italy with 36, Britain with 37, Spain with 14, France with 15 and South Korea with 33 companies.' Major Western energy groups such as Total of France, Norwegian Statoil and OMV of Austria, who have withdrawn from Iran, made a 'symbolic' appearance at the fair." (AFP, "Chinese Firms Dominate Iran Oil Exhibition," 4/15/11)

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"Oil and gas group OMV has not renewed a fuel supply contract with Iran's state airline because of international sanctions against the Islamic Republic, an Austrian newspaper reported. The move means Iran Air planes can no longer fill up at Vienna airport, the Wiener Zeitung reported in its weekend edition. The contract expired on March 23, it said." (Reuters, "Austria's OMV Ends Iran Air Fuel Contract," 3/27/10)

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"The U.S. Congress is moving toward passing a bill that would strengthen sanctions against Iran over that nation’s nuclear activities by putting greater pressure on Iran’s oil and gas sectors, both of which have underpinned Iranian President Mahmoud Ahmadinejad’s administration. Other companies named in the list, which was announced Thursday, include Austria’s OMV AG..."(Asia News Net, "Japan firms may face U.S. sanctions over Iran," April 25, 2010) 

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"The enormous New York State Common Retirement Fund plans to divest $86.2 million in investments from nine companies doing business in Sudan and Iran...The decision comes after two years of reviewing these companies, the potential risk of the investments and, in some cases, humanitarian efforts in these countries.'We don't expect our investments to benefit regimes that support genocide and terrorism,' said DiNapoli. The fund plans to divest out of $86 million in Gazprom (OGZPY), Inpex (1605.TO), Lukoil (LUKOY), Oil And Natural Gas Corp (500312.BY), OMV (OMVKY), Petroleo Brasilia (PBR), Statoil (STO), Wartsila OYJ and Sinopec Corp. DiNapoli said the firms were chosen because 'they failed to respond or we were not satisfied with their responses' when asked to provide information to the fund on the investments and their risks. (Dow Jones Newswires, "NY Comptroller To Divest $86.2M In State Pension Fund Investments," 6/30/09)

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"When Austria-based energy company OMV AG saw a chance to develop a lucrative Iranian gas field in April, it jumped at the $18 billion deal despite strong opposition from the U.S." (The Wall Street Journal, "U.S. Sanction Threats Make Little Headway," July 12, 2007)

Mercedes-Benz AG (“Mercedes-Benz”) was listed as a participant at the 16th International Exhibition of Transportation Urban Services & Related Industries (“ITUF”), which took place at the Tehran International Permanent Fairground from January 2-5, 2019. (ITUF 2019, “Exhibition Profile”).

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"Daimler (DDAIF) said in a statement that Iran's automotive markets have been significantly weaker than expected, and it had not yet resumed production or sale of Mercedes cars or trucks in the country. The company has not sold cars in Iran since 2010." (CNN Money, "Daimler abandons its Iran plans over US sanctions," 8/7/2018).

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"Emdad Khodro Iran has signed a deal with Setareh Iran, Mercedes-Benz's distributor in the country, to offer mobile emergency services to the products of the German manufacturer. Owners of Mercedes-Benz vehicles can purchase an Emdad Khodro subscription and make use of services, including rescue dispatchers, fuel supply, auxiliary battery and car transport, IKCO Press reported." (March 15, 2018)

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"Iran Khodro (IKCO) CEO Hashem Yekehzare announced that his company as the biggest car manufacturer in the Middle East has finalized five contracts with German automaker Mercedes Benz. "Iran Khodro and Mercedes-Benz have signed three contracts and two other contracts have been fully finalized," Yekehzare told reporters on the sidelines of a ceremony in Tehran on Saturday. He said that the details of the contracts between Iran Khodro and the German carmaker will be publicized soon." (Fars News Agency, "IKCO, Mercedes Benz Finalize 5 Joint Venture Contracts," 1/28/2017). 

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"The Iranian car manufacturing company Iran Khodro and the German Daimler concern signed an agreement on the start of production of Mercedes-Benz cars in Iran from the Islamic new year (late March), the ISNA news agency reported on Friday." (January 20, 2018).

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"Iran Khodro expects to sign a commercial deal with Mercedes-Benz within the next six months, the CEO of the Middle East’s biggest carmaker says. The two sides have already reached an agreement on production of commercial
vehicles and passenger cars in Iran. 'The current letter of intent will get down to signing in the first half of the next
(Iranian) year,' beginning on March 20, Iran Khodro Chief Executive Hashem Yekke-Zare said on Sunday." (Press TV, "Iran Khodro sees imminent Mercedes deal," 3/13/2016).

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"Iran Khodro Industrial Group (IKCO) and Germany’s car manufacturer Mercedes-Benz officially started a new round of cooperation with opening their joint company in Tehran. Setareh Iran company was inaugurated in a formal ceremony attended by German Ambassador to Iran Michael Freiherr von Ungern as well as a group of top managers from IKCO and Mercedes Benz….For his part, the CEO of Mercedes Benz Middle East Office, Steffen Boumann praised IKCO as the largest car manufacturer in the region saying IKCO’s
production lines enjoy a high quality. He emphasized the necessity of conducting new research into the regional markets, adding: 'We are of the opinion that IKCO has an enormous potential to produce Mercedes Benz vehicles.'
He concluded that the German company will enhance its cooperation with IKCO after conducting feasibility studies and establishing new production lines at IKCO sites in the near future." (Fars News Agency, “Iranian Automaker, Mercedes Benz Start New Round of Cooperation,” 2/27/2016).

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Mercedes Benz is listed as a participating company at the 14^th International Exhibition of Transportation & Urban Services & Related Industries which takes place October 27-30^th, 2016 in Tehran Iran. (Participating International Companies)  

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“Iranian car manufacturing company Saipa is in talks with France's PSA Peugeot Citroen and Renault, Germany's Mercedes-Benz, and Sweden's Volvo to finalize deals on joint production of cars in Iran, Saipa officials announced on Tuesday.  Saipa CEO Saeid Madani announced that the company is in negotiations with PSA Peugeot Citroen to sign a deal, but at the same time noted that any deal would depend on the ongoing talks between Tehran and world powers over the country's peaceful nuclear energy program…CEO of Saipa Diesel Za'far Tanhapour, who was also attending the ceremony, announced that the company has started talks with Germany's Mercedes-Benz, and expressed the hope that the talks would be finalized by the end of the current Iranian calendar year (mid-March).  Mercedes-Benz can be a good partner for Saipa Diesel, Tanhapour stressed, adding that joint projects for the development of products are high on Saipa's agenda.” (Tasnim, "Iran's Saipa Negotiating with European Automakers," 5/12/15)

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"[T]he auto sanctions were lifted earlier this year after an interim nuclear agreement was reached between Iran and world powers and a final accord is still on the horizon, raising the prospect of better times for the industry. That will draw international suitors to Tehran on Monday for the second consecutive Iran Auto Show. Mercedes Benz, Volkswagen, Renault, Peugeot, Kia and Toyota have confirmed [they will attend]." (Agence France-Presse, "Foreign automakers find Iranian market has gone local," 11/30/14)

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"Last week, Qorbani announced that Benz, Volkswagen, Volvo, Fiat, Rover, Skoda, Renault, Peugeot, Kia and Toyota would take part in the Iranian auto expo, adding that the US car-manufacturers would also join the event. 'In case of desirable conditions, General Motors and Ford companies will also attend the event.' He continued that some leading car parts makers, including Siemens, FORD Mendo, Busch, FRW and ACI would attend the gathering. The event will start work on December 10." (Fars News, "55 Giant Int'l Carmakers, Part-Makers to Participate in Iranian Auto Expo," 11/2/14)

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Iran Khodro Company (IKCO) will start cooperation with Germany's Mercedes-Benz Company once the sanctions on Iran's car industry are completely lifted, the Managing Director of IKCO Hashem Yekke Zareh said on December 1. 'We will start negotiations with French Peugeot Company in the coming days in order to restart the two companies' cooperation,’ the Mehr News Agency quoted Yekke Zareh as saying. (Trend, Iran Khodro Co. seeks cooperation with Germany’s Mercedes-Benz, 12/1/2014)

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"The nuclear deal struck by Iran and six world powers will put more rubber on the road in the Islamic Republic. The country’s major carmakers stand ready to start receiving parts again from French firms PSA Peugeot Citroen and Renault when the sanctions ease. That could see Iran’s stalled car production again take off, proving a boon to local automakers and potentially draw in more foreign investment from other manufacturers hoping to break into the market…Iran Khodro’s manager, Hashem Yekeh Zare, said his company is considering a joint project with Daimler AG’s Mercedes-Benz, but didn’t elaborate. Zare said his company is seeking greater self-sufficiency and is interested in importing auto parts and licenses for joint production." (Washington Post, "Iran nuclear deal hits gas pedal for carmakers," 11/30/13)

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The Setare Iran Company is currently negotiating with Mercedes-Benz to reopen the German company's production line in Iran, the Managing Director of Setare Iran Company Seyyed Reza Hosseini said on Friday. ‘The Iranian Top Khodro Company previously used to manufacture Mercedes-Benz sedan cars in Iran, but the production line is now at a halt. In the event of the negotiations succeeding and sanctions lifted, we can open the line,’ the Fars News Agency quoted Hosseini as saying. ‘Iran Khodro Diesel was also active in the production of Mercedes-Benz models, especially the E-Class series in Iran,’ he said, adding that Iran is still the exclusive base for production of the German company's model in the Middle East. (Trend, Iranian firm negotiates to reopen Mercedes-Benz production line in Tehran, 10/25/14)

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"The Trade Promotion Organization of Iran has announced the list of cars which are allowed to be imported in the current Iranian year, but renowned brands such as Porsche, Benz, BMW, Maserati, and Nissan are not in the list, ISNA news agency reported." (Azer News, "Iran bans imports of renowned car brands," 5/27/2013)

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Setareh Iran lists itself as the exclusive distrbutor of Mercedes-Benz in Iran.

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According to the website Intravel Card, "You can’t use MasterCard in Iran. Due to sanctions, Iran is forbidden to make any USD/EURO transaction to International banking system So, MasterCard in Iran is not accepted nor Credit card and Visa Card or any other debit cards. You can use Iran debit card like IntravelCard instead of MasterCard in Iran."

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In their Annual Report filed with the SEC for fiscal year 2021, Mastercard stated that "Iran and Syria have been identified by the U.S. State Department as terrorist-sponsoring states, and we [Mastercard] have no offices, subsidiaries or affiliated entities located in these countries and do not license entities domiciled there."

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On March 16, 2016, OFAC issued a Finding of Violation to Mastercard that stated: "The U.S. Department of the Treasury’s Office of Foreign Assets Control (OFAC) has issued a Finding of Violation to MasterCard International Incorporated (“MasterCard”) for violations of the Reporting,
Procedures and Penalties Regulations (RPPR), 31 C.F.R. part 501. On October 25, 2007, OFAC designated Bank Melli pursuant to Executive Order 13382 of June 28, 2005, “Blocking Property of Weapons of Mass Destruction Proliferators and Their Supporters,” and Bank Saderat pursuant to Executive Order 13224 of September 23, 2001, “Blocking Property and Prohibiting Transactions with Persons who Commit, Threaten to Commit, or Support Terrorism,” and added both parties to the List of Specially Designated Nationals and Blocked Persons (the “SDN List”).

At the time OFAC designated Bank Melli and Bank Saderat, MasterCard held accounts in which Bank Melli or Bank Saderat had an interest. MasterCard had previously taken steps to restrict the above-referenced accounts following the issuance of Executive Order 12959 of May 6, 1995, “Prohibiting Certain Transactions With Respect to Iran” (“E.O. 12959”), which prohibited the exportation of goods, services (including financial services), or technology from the United States to Iran. In the time between the issuance of E.O. 12959 and the above-referenced designations, the Bank Melli and Bank Saderat accounts became dormant on MasterCard’s books, but the assets in the accounts nonetheless remained with MasterCard. MasterCard, however, failed to report the accounts to OFAC as blocked following OFAC’s designation of the banks. By failing to properly report the abovereferenced accounts in which Bank Melli and Bank Saderat had an interest, MasterCard violated § 501.603(b) of the RPPR."

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According to its Annual Reports filed with the SEC in 2016, 2017, 2018, and 2019: 

We identified through our compliance program that for the period covered by this Report, Mastercard processed transactions resulting from:

•certain European acquirers having acquired transactions for consular services with Iranian embassies located in Austria, France and Spain that accepted Mastercard cards
•certain European and Middle Eastern acquirers having acquired transactions for Iran Air, which accepted Mastercard cards, in Austria, France and Qatar

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In 2017 the U.S. state of Michigan listed Mastercard as an Iran restricted company rendering Mastercard ineligible for investment and/or state contracting./ "MasterCard does not have any direct links with Iran due to the primary sanctions still in place, said the Central Bank of Iran’s head of Communications and Information Technology Department.

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“Although the US-based company provides no services in Iran, negotiations are underway with non-US international companies to offer international credit cards to Iranians, which will come to fruition next year,” Nasser Hakimi was also quoted as saying by ISNA." (March 4, 2017)

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An AP review of corporate SEC filings found dozens of companies that have done business in Iran in recent years or said their products or services may have made it there through other channels. Some are household names: PepsiCo, Tyson Foods, Canon, BP Amoco, Exxon Mobil, GE Healthcare, the Wells Fargo financial services company, Visa, MasterCard and the Cadbury Schweppes candy and beverage maker. (Associated Press, "From bull semen to bras, Iran still buys American," July 9, 2008)

The Lloyds Bank Group’s businesses, being reported below, are conducted in compliance with applicable laws in respect of Iran and Syria sanctions and, except as noted below, the Lloyds Bank Group intends to continue these historic activities until it is able to legally terminate the contractual relationships or to maintain/manage them in accordance with prevailing sanctions obligations. The nature of these activities is as follows: Limited and infrequent payments made to and received from entities directly or indirectly linked to the Government of Iran. Such payments are only made if they comply with UK regulation and legislation and/or licence from the U.S. Treasury Department’s Office of Foreign Assets Control. Since the introduction of an enhanced financial sanctions policy, the Lloyds Banking Group (including the Bank) has been proactive in reducing its dealings with Iran and individuals and entities associated with Iran. There remain a small number of historic Iran-related business activities which the Lloyds Banking Group has not yet been able to terminate for legal or contractual reasons. (3/26/2020)

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In 2018 and 2019 Lloyds was listed on the Texas Comptroller List of Companies Engaging in Scrutinized Business Operations in Iran.  
 

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Lloyds Banking Group PLC (a U.K. company) disclosed that, despite “reducing its dealings with Iran and individuals and entities associated with Iran,” two of its non-U.S. affiliates (Lloyds Bank PLC and Bank of Scotland PLC) received or made payments involving entities owned or controlled by the Iranian Government. Lloyds asserts that these payments (related to “historic guarantees”) were credited to blocked or frozen accounts, and specifically authorized under U.K. and EU sanctions laws. (SEC Disclosure)  

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"Since 2009, the Justice Department, the Treasury Department and the Manhattan district attorney’s office, working largely in concert, have brought charges against five foreign banks, contending they moved billions of dollars through their American subsidiaries on behalf of Iran, Cuba and North Korea, sponsors of terrorism and drug cartels. The cases against the five banks all included deferred prosecution agreements and required the banks — ABN Amro, Barclays, Credit Suisse, Lloyds and most recently ING — to forfeit a substantial amount of assets. The cases typically have not involved United States banks. Unlike foreign institutions, American banks were prohibited from originating or receiving such transactions from Iran. That enabled them to largely sidestep the conduct that has helped ensnare foreign banks." (New York Times, "Deutsche Bank’s Business With Sanctioned Nations Under Scrutiny," 8/17/12)

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"Lloyds TSB agreed to pay a $350 million fine to the United States government last year after an investigation found that the company had stripped information from transactions in order to channel Sudanese and Iranian money into the American banking system in violation of United States sanctions. Prior to the bank's decision to leave Iran in 2008, Lloyds received federal grants from the Farm Service Agency."  From 2000-2009, the company was the recipient of $20 million US federal funds.  They have withdrawn their investments in Iran.  (The New York Times, "Profiting from Iran, and the US," 3/6/2010)

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"Lloyds Banking Group PLC on Tuesday became the latest bank to reach a settlement with American authorities over the handling of funds for countries under U.S. sanctions such as Iran.  The U.S. Treasury's Office of Foreign Assets Control announced a $217 million settlement related to Lloyds's 'intentional manipulation and deletion' of information in wire-transfer instructions that were routed through third-party banks located in the U.S." (The Wall Street Journal, "Lloyds Settles U.S. Case Over Iranian Transactions," 12/23/09)

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“Evidence of Iran's efforts to acquire sensitive materials also is emerging from investigations by state and federal prosecutors in New York into whether a number of major Western banks illegally handled funds for Iran and deliberately hid Iranian transactions routed through the U.S….Documents detailing Iran's metals acquisition efforts are being reviewed by U.S. law-enforcement and intelligence officials, people involved in the matter said. Manhattan District Attorney Robert Morgenthau said he is conducting a broad inquiry into illegal transactions by Iran. Last week, Lloyds TSB of London agreed to pay $350 million to settle U.S. sanctions-busting charges with Mr. Morgenthau's office and the Justice Department. The bank admitted it violated U.S. law but said the practice has ceased. There are nine other banks that we think were doing this, said Mr. Morgenthau in an interview, including Barclays PLC of the U.K.  A Barclays spokesman had no comment beyond a prior disclosure confirming the inquiry. Other banks under scrutiny in the probe include Credit Suisse and Deutsche Bank, people with knowledge of the inquiries said." (The Wall Street Journal, "Fresh Clues of Iranian Nuclear Intrigue," 1/16/09)

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"Lloyds TSB has agreed to forfeit $350m (£231m) to law enforcement authorities in the US after admitting breaking ­international sanctions by secretly channelling Sudanese and Iranian money into the American banking system. In the biggest penalty ever levied for a breach of US sanctions, the British bank has accepted responsibility for criminal conduct in a case involving" (The Guardian, "Lloyds forfeits $350m for disguising origin of funds from Iran and Sudan," 1/10/09)

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"It also emerged at the end of March that three European banks--Barclays and Lloyds TSB, both of the UK, and Credit Suisse of Switzerland--face investigation by the US Justice Department and the New York district authorities over whether they purposely hid the origins or destinations of transactions in order to circumvent sanctions against Iran, Cuba, Sudan and Libya. The investigations follow a federal probe into a Dutch bank, ABN Amro, in 2005, after it was fined for obscuring references in wire transfers and processing payments involving Iran and Libya. The US Treasury Department said in a warning to financial institutions in March that banks in Iran disguised their involvement in proliferation and terrorism. Like many other European banks, Credit Suisse moved to cut ties with Iran at the end of 2005." (Economist Intelligence Units Country)

KPMG AG Partner Dr. Ulrich von Zanthier spoke at the 7th Banking & Business Forum Iran Europe (“the Forum”) at the Maritim Hotel in Berlin on October 18-19, 2018. (Maleki Website, “7th Banking & Business Forum Iran Europe”).

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April 2010: KPMG has ended its business relationships in Iran. (The New York Times, "Companies Feeling More Pressure to Cut Iran Ties," 4/24/10)

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"Bayat Rayan, a subsidiary of KMPG, has been operating in Iran since 1955. They are the number one international accounting firm in Iran, according to the company. KPMG also provides accounting and auditing services to the United States federal government."  From 2000-2009, the company was the recipient of $1.2 billion US federal funds.  Their business in Iran is currently active.  (The New York Times, "Profiting from Iran, and the US," 3/6/2010)

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Iran is part of KPMG’s MESA (Middle East & South Asia) region. Iran’s country profile lists that there are 60 KPMG professionals in Iran (KPMG Website, “Countries in KPMG’s MESA region”). “Bayat Rayan” is the member firm of the KPMG network representing the company in the country (KPMG, “Iran: Taxation of International Executives,” 2008).

In 2008, KPMG produced a 21-page Iran specific-report, "Taxation of International Executives" (KPMG, “Iran: Taxation of International Executives,” 2008).

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"In addition to its presence in UAE, KPMG is widely represented in the Middle East region and has offices in Bahrain, Qatar, Egypt, Kuwait, Lebanon, Jordan, Oman, Yemen, Saudi Arabia and Iran." (KPMG Release, “KPMG in the UAE announces the results of their business intelligence survey,” 12/17/08)

According to its Annual Report filed with the SEC for 2019: "ING has a policy not to enter into newrelationships with clients from these countries and processes remain in place to discontinueexisting relationships involving these countries. At present these countries are Cuba, Iran, North Korea, Sudan and Syria."

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ING Bank maintains a policy not to enter into new relationships with clients from Iran and processes remain in place to discontinue existing relationships involving Iran. (2017)

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ING Chairman Jeroen van der Veer provided a keynote address at the 3rd Europe-Iran Forum on May 3, 2016.  (Europe-Iran Forum Website, “3rd Europe-Iran Forum: Program”). 

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Despite hopes of a new dawn for Iran's economy after nuclear-related sanctions were lifted, major Western banks are reluctant to do business with the Islamic republic for fear of US retribution. President Hassan Rouhani has said that to reach the target of eight-percent growth needed to modernise the industrial sector and relaunch the hobbled economy, Iran needs up to $50 billion in foreign investment every year. But without the big foreign banks, that looks impossible. "For the moment, the little European banks have agreed to work with us," said Parviz Aghili, head of the private Middle East Bank in Tehran. They include banks from Italy, Austria, Switzerland, Germany and Belgium, he said without naming them. "But not a single medium-sized or big bank has so far agreed to do it," he added... The limited number of institutions that do deal with the Islamic republic include Raiffeisen Bank and Erste Bank from Austria, Mediobanca and Banco Popolare of Italy, Germany's EIH, KfW and AKA banks, Belgium's KBC, ING of the Netherlands and Turkey's Halk, according to a banking expert in Tehran. "These banks have established working relations with the Iranian banks to open letters of credit for fairly small sums of 10, 20 or 50 million dollars." But they lack the resources to finance big projects like the deal struck between Iran and European aircraft manufacturer Airbus for 118 airplanes, or oil and gas development projects, the expert said. (AFP, "Iran banking hobbled by Western reluctance to engage," 9/13/2016).

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"Since 2009, the Justice Department, the Treasury Department and the Manhattan district attorney’s office, working largely in concert, have brought charges against five foreign banks, contending they moved billions of dollars through their American subsidiaries on behalf of Iran, Cuba and North Korea, sponsors of terrorism and drug cartels. The cases against the five banks all included deferred prosecution agreements and required the banks — ABN Amro, Barclays, Credit Suisse, Lloyds and most recently ING — to forfeit a substantial amount of assets. The cases typically have not involved United States banks. Unlike foreign institutions, American banks were prohibited from originating or receiving such transactions from Iran. That enabled them to largely sidestep the conduct that has helped ensnare foreign banks." (New York Times, "Deutsche Bank’s Business With Sanctioned Nations Under Scrutiny," 8/17/12)

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"ING Bank [a subsidiary of ING Group,] has agreed to pay a record penalty of $619 million for illegally moving billions of dollars through the U.S. banking system on behalf of Cuban and Iranian clients and threatening to fire employees if they failed to conceal the origin of the money . . . the bank, a unit of ING Groep NV, one of the Netherlands largest banks, used a system to 'strip,' or delete, references to Cuba and Iran and, through more than 20,000 separate transactions, successfully moved more than $2 billion through the U.S. financial system . . . [ING] engaged in transactions with Iran's central bank and state-owned National Iranian Oil Co."  (Wall Street Journal, "ING Fined a Record Amount," 6/12/12)

Noted for conducting business with Iranian banks. (Avi Jorisch, "Iran's dirty banking," 2010)

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"Dutch bancassurer ING Group NV repeated that it could face 'significant' fines due to a U.S. investigation of operations in countries which are under sanctions by U.S. authorities, such as Iran and Cuba. The United States imposes economic sanctions and export controls on Cuba, Iran, Sudan and Syria, viewing them as state sponsors of terrorism and limiting the scope for companies to do business there... A U.S. judge last August approved a $298 million settlement by British bank Barclays Plc over charges that it had violated U.S. trade sanctions by doing deals in Cuba, Iran, Libya, Sudan and Myanmar."(Reuters, "ING says could face fines following U.S. investigation," 7/27/10) 

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Listed by U.S. Government as doing business in Iran. (U.S. Securities and Exchange Commission, List of Companies Doing Business With State Sponsors Of Terror, Removed from the internet in July of 2007)

"HP acquired the Apogee group, a U.K. based office equipment dealer, on November 1, 2018.  During the second quarter of 2019, HP discovered that its newly acquired subsidiary had invoiced one payment and accepted two payments from Bank Sepah International plc shortly after the acquisition, under a legacy contract for copier services.  Bank Sepah International plc is subject to U.S. sanctions pursuant to Executive Order 13382. The combined total value of the transactions was £72.49 ($92.78).  We are unable to accurately calculate the net profit attributable to these transactions.  Following HP’s discovery of these transactions and at HP’s direction, Apogee terminated the contract with Bank Sepah International plc.  HP is in the process of disclosing relevant transactions related to the Apogee acquisition to the relevant authorities." (SEC Disclosure, 5/30/2019)

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HP discovered that its newly acquired subsidiary, Apogee group, processed two service calls during November 2018, shortly after the acquisition, for toner replacement on behalf of Bank Saderat plc, with which it had a legacy contract. Following HP’s discovery of these transactions and at HP’s direction, Apogee terminated the contract with Bank Saderat plc. (SEC Disclosure, 12/12/2019).

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The Iranian company, DAYA SERVER, is engaged in the sale and support of HPE products. (DAYA SERVER Website, “Customers”). (DAYA SERVER Website, “Customers”). 

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 "HP has a policy of complete compliance with all US export laws. We don't sell products directly to Iran and we don't have any employees or facilities in that country. Having recently examined the situation, we believe it's important to go beyond the letter of the law. HP is taking further steps with distributors in the Middle East intended to prevent the distribution of our products in Iran by third parties. These actions include tightening distributor contract terms to explicitly prohibit the sale of HP products in Iran, more closely monitoring the activities of our distributors in the Middle East, and conducting even more frequent audits of our distributors in the region." (Company Website)

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“A major infiltration of a military network blamed on Iran was facilitated by a poorly written contract with computer-services provider Hewlett-Packard Co. , said people familiar with the matter. H-P's contract with the military didn't require it to provide specific security for a set of Navy Department databases, and as a result, no one regularly maintained security for them. That eased access for hackers, who used the opening to penetrate deep into the Navy Marine Corps Intranet network, said people familiar with the matter. The findings of the Navy's investigation are being closely watched by lawmakers on Capitol Hill, who next week are set to evaluate the nomination of Vice Adm. Michael Rogers as National Security Agency director. Adm. Rogers was the Navy cyber chief who oversaw the response. The intrusion, which officials said didn't compromise classified information or email, took about four months to clean up. The Navy has been working to address lapses revealed by the hack and other security efforts under what it calls Operation Rolling Tide. The infiltration is the only publicly known penetration of a military network blamed on Iranian hackers…The hacking ‘is a contracting failure and not a technology failure,’ said one cybersecurity specialist familiar with the situation. ‘This is a Dilbert cartoon.’ H-P on its website calls the Navy and Marine Corps network ‘the world's largest and most secure intranet,’ saying that ‘improved security is unquestionably NMCI's greatest value.’ The network's security system detects more than 800 new viruses each month, it says. An H-P spokesman declined to comment on the infiltration.” (Wall Street Journal, “Navy Hacking Blamed on Iran Tied to H-P Contract,” 3/6/14)

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"A major Iranian partner of Huawei Technologies offered to sell at least 1.3 million euros worth of embargoed Hewlett-Packard computer equipment to Iran's largest mobile-phone operator in late 2010, documents show. China's Huawei, the world's second largest telecommunications equipment maker, says neither it nor its partner, a private company registered in Hong Kong, ultimately provided the HP products to the telecom, Mobile Telecommunication Co of Iran, known as MCI... Huawei has a similar partnership with HP. In a statement, the Palo Alto, Calif., company said, 'HP has an extensive control system in place to ensure our partners and resellers comply with all legal and regulatory requirements involving system security, global trade and customer privacy and the company's relationship with Huawei is no different.' The statement added, 'HP's distribution contract terms prohibit the sale of HP products into Iran and require compliance with U.S. and other applicable export laws.'... The proposal makes clear that HP computer servers were an integral part of the 'Hardware Installation Design' of the expansion project. Tables listing equipment for MCI facilities at a new site in Tehran and in the city of Shiraz repeatedly reference HP servers under the heading, 'Minicomputer Model.'... The pages list prices for HP servers, disk arrays and switches, including those that already are 'existing' and others that need to be added. The total proposed project price came to 19.9 million euros, including a 'one time special discount.' The proposed new HP equipment, which totaled 1.3 million euros, included one server, 20 disk arrays, 22 switches and software . The existing HP equipment included 22 servers, 8 disk arrays and 13 switches, with accompanying prices. Asked who had provided the existing HP equipment to MCI, Vic Guyang, a Huawei spokesman, said it wasn't Huawei." (Reuters, "Exclusive: Huawei partner offered embargoed HP gear to Iran," 12/30/12)

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"But because its products are often sold by others through indirect channels without its knowledge or consent 'it is always possible that products may be diverted to Iran or Syria after being sold to channel partners, such as distributors and resellers,' HP said... HP said in both letters that it would continue to work with ZTE, but it had conducted an internal investigation relating to an alleged sale of its products to MTN Irancell, Iran's second largest mobile carrier." (Reuters, "HP says products may have been sold to Syria by others," 11/23/2012)

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"MTN Irancell, a joint venture between MTN Group Ltd of South Africa and an Iranian government-controlled consortium, sourced equipment from Sun Microsystems Inc, Hewlett Packard Co and Cisco Systems Inc, the documents and interviews show. MTN owns 49% of the joint venture but provided the initial funding." (Reuters, "Iranian cell-phone carrier obtained banned U.S. tech," 6/4/2012)

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"Hewlett-Packard formed a partnership in 1997 with a newly formed company in Dubai to sell its products in the Middle East, including to Iran. It also sold services to the U.S. military while operating in Iran. In January 2009, after its sales in that country came under scrutiny, the company said it would cease all business in Iran to go "beyond the letter of the law."  From 2000-2009, the company has been the recipient of $17.6 billion US federal funds.  They have withdrawn their acitivites in Iran.  (The New York Times, "Profiting from Iran, and the US," 3/6/2010)

"Amid rising tensions between Iran and the US, five missiles were fired at an “American oil company,” according to the Iranian Fars News website. The report is based on another Iraqi report that said Monday morning that rockets had been fired at a company linked to Halliburton. How the website knew this is unclear and photos were not available from the scene. It was also unclear who fired the alleged rockets; it could also be blamed on ISIS.

However, the alleged rocket attack fits a pattern of dozens of such attacks on bases housing US troops and against the American Embassy. In 2018, there were also attacks on US facilities in Basra, and the oil fields were largely evacuated of some foreign workers. The US evacuated its consulate in Basra and warned Iran and its proxies against attacks. Social justice protesters in October and November 2019 blocked roads to the oil fields around Basra." (4/6/2020)

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"This license authorized the company's United States personnel to engage in transactions relating to PSL Energy Service's oil drilling equipment. In response to questions from The New York Times, OFAC said that PSL Energy Services, a Scottish oil services company, had removed the equipment from Iran after completing a project there. It was in negotiations for the sale of a majority of its stock to Halliburton. Because the equipment was among the PSL's assets and had been used in Iran, it was deemed 'Iranian-origin goods' under American regulations, and thus a license was needed to allow Halliburton to deal with the equipment in the future. Shortly after OFAC issued the license, Halliburton completed the deal to acquire PSL Energy Services and announced it, records show." (New York Times, "Licenses Granted to U.S. Companies Run the Gamut," 12/24/10)

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"This license authorized the company to engage in transactions that ultimately would allow it to withdraw from Iran. The withdrawal came after the company was criticized for doing business in Iran's lucrative energy sector through a loophole that allows foreign subsidiaries of United States companies to do business in sanctioned countries or with sanctioned entities, activities that would be forbidden for the American parent." (New York Times, "Licenses Granted to U.S. Companies Run the Gamut," 12/24/10)

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"Halliburton, former Vice President Cheney's old company, provided oil and gas drilling services to Iran through foreign subsidies. After a political furor erupted over the work, the company announced it would do no new business in Iran, and it exited the country altogether in 2007. While still operating in Iran, Halliburton won huge contacts from the federal government, including a no-bid contract to restore Iraq's oil sector, as did its subsidiary at the time, Kellogg Brown & Root." From 2000-2009, the company was the recipient of $27.1 billion US federal funds.  The company has withdrawn its investments from Iran. (The New York Times, "Profiting from Iran, and the US," 3/6/2010)

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"More importantly, even the threat of unilateral sanctions has been effective as recently as last year. As state after state has ramped up efforts to divest pension funds from companies invested in Iran, and as S 970, the Smith-Durbin Iran Counter-Proliferation Act, has garnered support in Congress, American companies like General Electric, Halliburton, and Baker Hughes with subsidiaries operating in Iran have rethought the wisdom of doing business with one of our nation's most dangerous enemies. And as the United States has contemplated additional unilateral banking sanctions on Iran, banks across Europe have ratcheted back their exposure to the Islamic Republic, with some pulling out entirely." (AEI, "The Iran Counter-Proliferation Act of 2007," Danielle Pletka, April 21, 2008)

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"A top executive of Halliburton Company told lawmakers here yesterday that the corporation does not intend to resume business in Iran now that it has completed its current contracts. Testifying before a Senate subcommittee investigating American business ties to Iran, a Halliburton vice president and corporate secretary, Sherry Williams, said that when company officials decided to leave Iran in 2005, 'We recognized that we would not be able to go back in' under federal law." (The New York Sun, "Halliburton Says It Has No Plans To Go Back To Iran," Russell Berman, May 1, 2007)

"ExxonMobil did business with Iran, Syria and Sudan through a European subsidiary while President-elect Donald Trump’s nominee for secretary of State was a top executive of the oil giant and those countries were under U.S. sanctions as state sponsors of terrorism, Securities and Exchange Commission filings show. That business connection is likely to surface Wednesday at a confirmation hearing for ExxonMobil CEO Rex Tillerson before the Senate Foreign Relations Committee. The sales were conducted in 2003, 2004 and 2005 by Infineum, in which ExxonMobil owned a 50% share, according to SEC documents unearthed by American Bridge, a Democratic research group. ExxonMobil told USA TODAY the transactions were legal because Infineum, a joint venture with Shell Corporation, was based in Europe and the transactions did not involve any U.S. employees. The filings, from 2006, show that the company had $53.2 million in sales to Iran, $600,000 in sales to Sudan and $1.1 million in sales to Syria during those three years." (USA Today, "ExxonMobil and Iran did business under secretary of State nominee Tillerson," 1/9/2017).

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According to an Iran Notice filed with the SEC in 2013: "The captioned Act was signed by President Obama on August 10, 2012.  Among other things, the Act extended the prohibition against U.S. persons doing business with the Government of Iran to include such persons’ non-U.S. subsidiaries.  Previously, non-U.S. subsidiaries were not covered by this restriction.  Application of the restriction to non-U.S. subsidiaries took effect on October 10, 2012.  The Act also requires registrants to disclose, in their annual and quarterly reports, activities covered by the Act which occurred anytime during the period covered by the report, even if such activities occurred prior to the effective date of the Act and were permitted at the time.

During the period from January to September, 2012, ExxonMobil’s majority-owned Canadian affiliate, Imperial Oil Limited (IOL), made several fleet sales of motor fuel with an aggregate total sales price of approximately 11,000 Canadian dollars to the Iranian Embassy in Canada.  IOL’s net profits attributable to these sales were less than 500 Canadian dollars.  The sales were made without the involvement of any U.S. person and were permitted by U.S. laws in effect at the time.  No sales occurred after the October 10, 2012, effective date, and we do not expect any such sales to occur in the future."

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"Infineum U.K., a joint venture in which ExxonMobil has a 50 percent indirect ownership, sold gasoline additives to Iran, but stopped in 2006, according to Cynthia Bergman White, company spokeswoman. Exxon is a big supplier of fuel to the Department of Defense." From 2000-2009, the company has been the recipient of $4.9 billion in US federal funds.  They have withdrawn their investments from Iran. (The New York Times, "Profiting from Iran, and the US," 3/6/2010)

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"An AP review of corporate SEC filings found dozens of companies that have done business in Iran in recent years or said their products or services may have made it there through other channels. Some are household names: PepsiCo, Tyson Foods, Canon, BP Amoco, Exxon Mobil, GE Healthcare, the Wells Fargo financial services company, Visa, MasterCard and the Cadbury Schweppes candy and beverage maker." (Associated Press, "From bull semen to bras, Iran still buys American," 7/9/08)